Explore perspectives on international tax, transfer pricing, IC-DISC, and the decisions shaping global business.
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Multinational enterprises (MNEs) that import goods from related parties face a complex challenge at the intersection of two distinct regulatory regimes: transfer pricing and…
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As IRS enforcement intensifies, mid-market multinationals are asking a critical question: Is standard transfer pricing documentation enough — or is an Advance Pricing Agreement…
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Transfer pricing adjustments are expensive. Transfer pricing penalties are worse. Under Internal Revenue Code Section 6662(e) and (h), the IRS can impose substantial penalties…
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Transfer pricing enforcement is entering a more aggressive phase. Increased IRS funding, data analytics capabilities, and global coordination with foreign tax authorities are reshaping…
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Introduction: Documentation Fails Long Before the Audit Starts Most companies assume poor transfer pricing documentation only becomes a problem if they are audited. That…
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Introduction: Compliance Language Is Lagging Economic Reality Most U.S. exporters believe that if their transfer pricing is “arm’s length,” they are protected. That assumption…
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Introduction: Tax Issues Don’t Kill Deals—Surprises Do Private equity firms expect tax complexity. What they don’t tolerate are undisclosed risks, unsupported structures, and post-close…
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The Foundation of Audit Defense In the world of international taxation, transfer pricing documentation is more than a compliance formality — it’s your first…
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Bridging the Gap Between Design and Execution Many multinational groups invest heavily in developing robust transfer pricing policies — benchmarking studies, comparability analyses, and…
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